Information on the Monkstown Ring Road

27 June 2006

Monkstown Ring Road Decision by An Bord Pleanála

Dear Residents,

An Bord Pleanála has approved the proposed Monkstown Ring Road with 13 conditions. Most of these conditions ensure that the Council builds higher boundary walls adjacent to the road as well as some pedestrian facilities. While these conditions do represent an improvement on Dún Laoghaire Rathdown County Council’s original plan I still believe this road project is a poorly planned piece of infrastructure.

Having spent considerable time at the Oral Hearing arguing against the road I am disappointed at this outcome. The Green Party felt that this road was inappropriate and would attract more traffic onto residential streets. We will continue to oppose the plan and press the Council to provide more support for improved bus, DART and Luas links as well as pedestrian and cycling facilities. I believe that the new road will result in large volumes of commuter transport passing through quiet residential areas. I also believed the destruction of the cottages on Yankee Terrace could have been avoided.

My Green Party colleagues on the Council will now seek to have the road removed from the County Development Plan, but it is unlikely that we will receive support from the other political parties on the Council. Some of you may also wish to seek a judicial review of the decision, but again I feel that this is unlikely to succeed. I have attached a link to the Bord’s decision and the Inspector's Report, and my own submission to the hearing may be viewed below. 

Please feel free to contact either myself or your local Green Party Councillor, Nessa Childers - 14 Gledswood Avenue, Clonskeagh, Dublin 14, 087 239 6396 or nchilders@cllr.dlrcoco.ie – to discuss this or any other issue.

Sincerely,

Ciarán Cuffe TD
 

Link to An Bord Pleanála Website: 

http://www.pleanala.ie/monk.html

Monkstown Ring Road Submission at Oral Hearing from Ciarán Cuffe TD,
2 February 2005


Introduction
My name is Ciarán Cuffe. I am a TD representing the Dáil Constituency of Dún Laoghaire. I am also an architect and a town planner.

I ask that the application from Dún Laoghaire Rathdown County Council for approval for the Monkstown Ring Road be rejected by the Board.

It should be rejected for two reasons. Firstly the Environmental Impact Statement is gravely deficient in its content. Secondly, and more significantly it is a poor transport proposal.

The alternative of a do-nothing or a do-minimum should be considered. This could include enhanced public transport provision and traffic management and/or pedestrian and cycling linkages through the area.


Deficiencies
Mr. Inspector the EIS is inadequate in content; it conceals the views of the County Architect that Yankee Terrace should be retained; it naively assumes that new roads are good for business. It fails to take into account the tendency of new roads to create traffic and it under-estimates their tendency to attract traffic.

Information
Insufficient information has not been made available in a timely manner for third parties to assess the proposal. I understood that the ‘Monkstown Ring Road Environmental Impact Statement dated July 2005, with page number up to 101 and which included fold-out figures was the Local Authority’s application to the Board for approval. I am happy for the Applicant to expand that information with the statements from a dozen witnesses to date. However I am concerned at the reference to additional folders of information that have been placed at the rear of this room, which I have not had the chance to study, and which have not been copied and circulated to those who have made observations. I also note that an additional Report from the County Architect was submitted on day three of the hearing.

The mapping information made it difficult to differentiate buildings from open space, and the traffic model mapping was difficult to follow. In addition it appears that different cordons were used for traffic modelling, building assessment, and the investigation of flora and fauna habitats.

Amenities / Conservation
I am concerned that three days into the hearing we were given a report by the County Architect Mr. Derek Jago that recommends that the sixteen buildings due for demolition should be retained. This is an extraordinary admission by one of the most senior officials in the County Management team.

During the Vietnam War the journalist Peter Arnett quoted an unnamed American General as stating: "We had to destroy the village in order to save it."

Similar sentiments seem to be behind the proposal that we demolish sixteen homes and somehow rejuvenate Newtown Park Village.

The proposed road would lead to a significant loss of amenity for those living adjacent to the proposed route.

The plan proposes the acquisition and demolition of sixteen homes. It will bring high volumes of traffic onto Fleurville and Brookville Park. There will be a reduction of open space at Fleurville; Up to eighty trees will be felled. It will be very difficult for residents to cross the new road.

I am concerned at the loss of built heritage, and particularly the loss of sixteen homes if the scheme proceeds. Housing is in high demand in the County, and this is a significant loss.

I don’t believe that due consideration has been given to the worth of these buildings.
The Planning Act 2000 states:

For the purpose of protecting structures, or parts of structures, which form part of the architectural heritage and which are of special architectural, historical, archaeological, artistic, cultural, scientific, social or technical interest, every development plan shall include a record of protected structures, and shall include in that record every structure which is, in the opinion of the planning authority, of such interest within its functional area.
Planning and Development Act 2000 Section 51.— (1)

I would expect an E.I.S. to at least examine the existing buildings under these headings yet I do not believe that this has occurred. I also don’t believe that sufficient attention has been given to the intrinsic worth of these homes within the main EIS document. The loss of all of these buildings amounts to more then their individual value. It is the dramatic reduction in the quality of the built environment in the heart of the village.


Economics
On economic issues, it has simply and naively stated that the road will bring economic benefits.

The United Kingdom Standing Advisory Committee for Trunk Road Assessment (SACTRA) issued an interim Report on 16 March 2000 entitled ‘Transport investment, transport intensity and economic growth’. In essence it stated that one should be cautious in jumping to the conclusion that the provision of transport investment will be beneficial. There may be winners and losers.

While in certain circumstances transport schemes may bring added economic benefits to an area needing regeneration, in other circumstances the opposite might occur. Better communications will enlarge markets for goods, services and workers: the area as a whole may gain or lose from this depending on the structure and competitiveness of the local economy. It follows that there is no simple, unambiguous link between transport provision and local regeneration.
‘Transport investment, transport intensity and economic growth’ SACTRA, 2000

Mr. John McDaid stated:

“The cohesion of the new county requires …. A corridor between the three established town centres in the County.”

I assume he means Dundrum, Stillorgan and Dun Laoghaire. However the County is an artificially constructed entity, and it is a curious idea to suggest that the Monkstown Ringroad will bring a magical cohesion to the County. People in the County of Dún Laoghaire Rathdown look to the City of Dublin as the main retail centre. If they live in Dún Laoghaire they shop there. If they live in Blackrock, them Blackrock is their focus. Likewise Dundrum and Stillorgan. People in Cabinteely, Shankill and Ballybrack also have a sense of identity and economic spend related to their town, village or parish.

It is an artificial construct to suggest that the County will thrive if the three towns mentioned by Mr. McDaid are strung together with a new road. It may be that Blackrock and Deansgrange may suffer, but there is no depth of economic analysis to the changes that a new road might bring to the County.

Ms. Henchy stated:

“To improve the attractiveness for residents to shop within this County it is important to improve links between these retail centres and the communities they serve in this case particularly the district centres at Stillorgan and Dun Laoghaire.”
Statement of Evidence – Planning Mary Henchy

If they become more attractive it stands to reason that they will attract more customers. That means they will generate more traffic, and yet the traffic model failed to take this into account. This is a significant flaw in the modelling process.

I would also suggest that some retail outlets could suffer from a reduction in passing vehicular traffic such as the proposed Centra shop on Newtown Park. At the very least I would have expected some process of contacting the retailers in the area to assess their opinion.


Traffic Generation
The EIS has not adequately addressed the propensity of new roads to generate and induce traffic.

Kenworthy and Newman argue from their worldwide survey of cities that the goal of "free-flowing" traffic (through such strategies as road widenings) actually results in MORE fuel consumption and air pollution.

"Does free flowing traffic save fuel (and lower emissions) in a city? This question is often asked in response to our contention that traffic [calming] will ease automobile dependence and gasoline use; it is generally asserted that building up congestion will in fact make cars use more fuel and we will be worse off than before...There is a longstanding observation that automobiles get high miles per gallon in smooth, free-flowing traffic and poor miles per gallon in stop-start, congested traffic..."
‘Does Free-Flowing Car Travel Reduce Fuel Consumption and Air Pollution? Cities and Automobile Dependence’ (1989)


One form of research bias is that of looking only at the emissions from individual cars, and not taking into account the inevitable changes in travel behavior that result when cars move faster and more freely. When conditions change to allow easier use of the car, people will inevitably drive more often and further, and are more likely to use a car instead of walking, bicycling or using the bus. This is because it becomes more unsafe and unpleasant to walk, bicycle, or ride the bus when travel by car is easier and more frequent. In other words, car travel tends to be a "zero sum game" -- that is, when we design our streets to improve conditions for cars, we almost inevitably worsen things for other forms of travel.

An increase in road capacity leads to an increase in traffic volumes using the routes in relation to which potential timesavings have been enabled. This is particularly so in situations of urban congestion.

Induced demand is the phenomenon that after supply increases, more of a good is consumed. This is entirely consistent with the economic theory of supply and demand, however has become important in the debate over the expansion of transportation systems.

This phenomenon has been empirically verified in a number of studies and accepted as real by official working groups and review bodies. In the United Kingdom, the Standing Advisory Committee on Trunk Road Assessment (SACTRA) published its report entitled Trunk Roads and the Generation of Traffic in 1994. As a result of this report, all analyses of road proposals in the UK are required to assess the impact of induced traffic, which would result from the proposal.

The phenomenon of induced traffic means that it is generally impossible to reduce congestion or improve air quality by providing more road space.


Mr. Inspector, with your permission I will read into the record an extract from a paper by Todd Litman referring to the issues of generated and induced traffic. I am concerned that the traffic modelling fails to consider current thinking on these issues.

“Traffic congestion tends to maintain equilibrium. Congestion reaches a point at which it constrains further growth in peak-period trips. If road capacity increases, the number of peak-period trips also increases until congestion again limits further traffic growth. The additional travel is called “generated traffic.” Generated traffic consists of diverted traffic (trips shifted in time, route and destination), and induced vehicle travel (shifts from other modes, longer trips and new vehicle trips). Research indicates that generated traffic often fills a significant portion of capacity added to congested urban road.

Generated traffic has three implications for transport planning. First, it reduces the congestion reduction benefits of road capacity expansion. Second, it increases many external costs. Third, it provides relatively small user benefits because it consists of vehicle travel that consumers are most willing to forego when their costs increase. It is important to account for these factors in analysis. This paper defines types of generated traffic, discusses generated traffic impacts, recommends ways to incorporate generated traffic into evaluation, and describes alternatives to roadway capacity expansion.

Planners often compare traffic to a fluid, assuming that a certain volume must flow through the road system. But urban traffic may be more comparable to a gas that expands to fill available space (Jacobsen, 1997). Road improvements that reduce travel costs attract trips from other routes, times and modes, and encourage longer and more frequent travel. This is called generated traffic, referring to additional vehicle traffic on a particular road. This consists in part of induced travel, which refers to increased total vehicle miles travel (VMT) compared with what would otherwise occur (Hills, 1996).

Generated traffic reflects the economic “law of demand,” which states that consumption of good increases as its price declines. Roadway improvements that alleviate congestion reduce the generalized cost of driving (i.e., the price), which encourages more vehicle use. Put another way, most urban roads have latent travel demand: additional peak-period vehicle trips that will occur if congestion is relieved. In the short-run generated traffic represents a shift along the demand curve: reduced congestion makes driving cheaper per mile or kilometre in terms of travel time and vehicle operating costs. Over the long run induced travel represents an outward shift in the demand curve as land use patterns and transport systems become more automobile dependent, and so people must drive more to maintain a given level of access to goods, services and activities (Lee, 1999).

This is not to suggest that increasing road capacity provides no benefits, but generated traffic affects the nature of these benefits. It means that road capacity expansion benefits consist more of increased peak-period mobility and less of reduced traffic congestion.

Accurate transport planning and project appraisal must consider these three impacts:

1. Generated traffic reduces the predicted congestion reduction benefits of road capacity expansion.

2. Induced travel imposes costs, including downstream congestion, accidents, parking costs, pollution, and other environmental impacts.

3. The additional travel that is generated provides relatively modest user benefits, since it consists of marginal value trips (travel that consumers are most willing to forego).

Ignoring these factors distorts planning decisions. Experts conclude:
“...the economic value of a scheme can be overestimated by the omission of even a small amount of induced traffic. We consider this matter of profound importance to the value-for-money assessment of the road programme”
United Kingdom Standing Advisory Committee for Trunk Road Assessment (SACTRA), 1994

And,
“…quite small absolute changes in traffic volumes have a significant impact on the benefit measures.
Ibid

Any evaluation of a roading project must include an assessment of its wider impacts and the long term social, environmental and economic consequences of creating further incentives for private car use. By assuming that traffic induction does not occur benefits are overstated and costs underestimated…”

‘Generated Traffic and Induced Travel Implications for Transport Planning’
Todd Litman, Victoria Transport Policy Institute, 10 May 2005

In conclusion, it is a significant omission not to adequately take into account induced and generated traffic, and the inclusion of this traffic may eliminate any benefits that that may be attributed it the construction of this road.

From what I can gather the traffic model being used appear to take some account of traffic that diverts its route, but does nor take into account induced vehicle travel. In addition the Cordon selection had been used as a limiter for taking into account generated traffic. This means for instance that trips from Shankill to Dublin that might have been taken by DART and that are now transferred to car travel via the Monkstown Ring Road because of the choice that the new road offers are not taken into account in the model.

Alternatives
The EIS has failed to adequately consider alternative proposals to the preferred road such as a ‘do-nothing’ option or enhanced provision for the ‘slow modes’ and public transport.

Such provision might include upgrading the cycle and pedestrian route that exists in rudimentary form between Springhill Park and Newtown Park via Mount Albany. It could be enhanced by the provision of more buses to Dublin Bus or others. It could be enhanced by the making available of a Government school bus service within the County similar to that which operates in rural areas.

If we are to make direct links along the Monkstown Ring Road corridor the Council could consider a pedestrian and cycle route along the corridor, but it would be crucial that residents would support such a measure. Another proposal that has been suggested by Mr. Brian Guckian is the idea of a ‘Greenway’ bus route along the corridor with restricted access to public transport vehicles and the slow modes. Again public support from the residents would be crucial for such a proposal to succeed.

I am at a loss as to why the Local Authority did not consider these and other proposals. The lack of consideration of these options dramatically devalues the value of the Environmental Impact Statement, and the process of Environmental Impact Assessment that we are witnessing today.


Poor Transport proposal

“Adding lanes to solve traffic congestion is like loosening your belt to solve obesity,” wrote Glen Hemistra in a letter to the English Independent in December 2002

No clear need for the road has been established within transportation plans for the Dublin Metropolitan Area. The alternative of not building the road, and investing in public transport and traffic management measures has not been considered in sufficient detail

I believe that the DTI recognised this where it stated:

“…proposed road schemes within the established urban area inside the C-Ring will have to demonstrate their worth in terms of safety and environmental benefits for residential and commercial areas (excluding those arising from any increase in peak period radial road capacity).
Dublin Transportation Initiative, Final Report 1994 10.6.2, p146


We must also reconsider the benefits of creating additional road space as a solution to our traffic problems. Significant Government Policy Documents published regarding Transportation include the following:

-‘Dublin Transportation Initiative Report’, 1994

-‘A Platform for Change’, Dublin Transportation Office, 2000

-‘Transport 21’, Department of Transport, 2005

These documents take a measured view of the value of new road construction within the M50 cordon. The Dublin Transportation Initiative Report that states that there would be no significant increase in the provision of road space within the M50 ring road. Transport 21 does not appear to make any strong argument for increased road provision in urban areas.

A significant amount of the proposed Road would be single-carriageway, thus making it difficult to provide for improvements in public transport through bus priority in a meaningful and significant manner. The EIS mentions the need to improve public transport links, but I don’t believe that there is any guarantee of new bus route provision on the alignment of the proposed road.

It is a flawed proposal to run a high volume traffic route through a quiet residential street that has dozens of driveways that will open directly onto the carriageway. This is a significant traffic hazard that does not have to happen. Mr. John McDaid stated in his oral evidence that the road is a “direct district distributor.” The EIS states on page 5 that it is an “integral part of the strategic road network of the county”. I believe there may be some confusion as to what the exact role of the road will be.

Either way it will attract tens of thousands of vehicles every day into what currently are quiet residential cul-de-sacs. I believe it to be the wrong road, in the wrong place for the wrong reasons.

Changing Approaches to Transport Planning
Over the last ten or fifteen years there has been a radical transformation in thinking regarding the provision of new road space in urban areas.

James Howard Kunstler stated:
“The 20th Century was about getting around. The 21st Century will be about staying in a place worth staying in.”
‘Geography of Nowhere: The Rise And Decline of America's Man-Made Landscape’, James Howard Kunstler Simon and Schuster, 1994

Another way of expressing this change is to state that twenty years ago we felt that there were engineering solutions, and now there is more thought going into management solutions. The engineering is expensive, and involves a lot of concrete and tarmacadam. The management can involve changing the sequence of traffic signals, changes in road marking, or even making a decision that the do-nothing option is the best one. If engineering belonged to the twentieth century, then management belongs to the twenty-first.


National Policy
The proposed road would appear to be odds with several Government Policies including the following:

-‘National Sustainable Development Strategy 1997-2002’, Government of Ireland, 1997

-‘National Climate Change Strategy’, Government of Ireland, 1997

-‘Ready, Steady, Play: A National Play Policy 2004-2008’, National Children’s Office, 2004


‘Ready, Steady, Play: A National Play Policy 2004-2008’ stresses the importance of play areas located close to children’s homes. As an observer commented at one of the meetings held in the Guardian Angels School the children in the area living in Fleurville and Brookville Park currently play tag on, cycle on and play on their roads, as they are residential cul-de-sacs.

‘The National Children’s Policy: Our Children – Their Lives’ states that “Children will have access to play, sport, recreation and cultural activities to enrich their experience of childhood”.

Furthermore, ‘Ready, Steady, Play: A National Play Policy 2004-2008’ states that: “A key issue to be addressed is the need for accessible areas for children to congregate and socialise freely” and recognises that ‘children’s play happens wherever children are’. The ability of children to congregate and play in their own neighbourhood will be greatly restricted if this road is built.

The ‘National Climate Change Strategy’ stresses the need to decrease emissions from the transport sector. According to ‘The National Climate Change Strategy’:

“Investment in public transport “has significant potential to reduce reliance on the private car for transport needs especially in urban areas with reductions in congestion and emissions, particularly in the Dublin area, and to secure more energy-efficient public transport, with consequential reductions in greenhouse gas and locally polluting emissions.”

It is not clear how reductions in Ireland’s greenhouse gas emissions will be facilitated by the construction of a new road.

The ‘National Sustainable Development Strategy’ states that:

“Large problems are often the result of many individual actions so individual and consumer behaviour needs to change to better support sustainable development policy objectives in areas such as transport, energy, waste, water, and consumption generally. The need for such change is evident in Ireland today where recent years have seen an increase in environmental pressures closely related to personal consumption – for example, increasing car numbers, growing waste volumes, and greater development pressures.”

It is not clear that the construction of the road would change the modal split in favour of public transport or the ‘slow modes’.

Finally there are concerns regarding the scoping of the project and about the methodology in certain areas of the EIS. The alternative of a do-nothing or a do-minimum should be considered. This could include enhanced public transport provision and traffic management and/or pedestrian and cycling linkages through the area.

In conclusion, I believe that the proposal should be dropped and that more should be done to encourage the provision of improved Luas, DART and bus transport in this area, as well as encouraging the ‘slow modes’ of cycling and walking’. If the County does find a spare €15 million, perhaps they would be better off spending it on improving amenities in the area such as the Dún Laoghaire and Blackrock Baths. If they do want to spend the money on transport infrastructure, then perhaps they could purchase fifty or one hundred vehicles for Dublin Bus. That would make a dramatic and real improvement to public transport provision in the County.

Ciarán Cuffe TD, 2 February 2006